Coastal Clarity Allied Health is committed to protecting the privacy, confidentiality and security of personal information entrusted to us by children, young people, parents, carers, participants, clients and other individuals.
Coastal Clarity Allied Health handles personal information responsibly and in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), where applicable, as well as relevant professional, contractual and regulatory requirements.
This policy explains how Coastal Clarity Allied Health collects, uses, stores, accesses and discloses personal information and how privacy and confidentiality are maintained.
Scope
This policy applies to personal and sensitive information handled by Coastal Clarity in connection with its services and business activities. It applies to information held in electronic or paper records, clinical records, practice management systems, email, website forms, photographs, recordings and other communication systems.
Information We Collect and How We Collect It
The information Coastal Clarity Allied Health collects depends on how an individual interacts with us and the services they receive.
We may collect information including:
- name, date of birth and contact details;
- parent, guardian, carer and emergency contact details;
- appointment, referral and service information;
- health, developmental and disability information;
- assessment information, clinical observations and reports;
- education and support information;
- NDIS, Medicare, private health insurance or funding information, where applicable;
- correspondence and communications;
- billing and payment information; and
- photographs, recordings or other information where appropriately authorised.
Health and disability information is sensitive information and will be handled with additional care. Where practicable, information will be collected directly from the individual, parent, carer or authorised representative. Where appropriate and permitted by law, information may also be received from health professionals, schools, support providers, government agencies, funding bodies or other authorised persons.
How We Use Personal Information
Coastal Clarity Allied Health may use personal information to:
- respond to enquiries and manage appointments;
- assess and provide services;
- develop and review support plans;
- prepare reports and maintain records;
- communicate with clients, families, carers and authorised representatives;
- coordinate services with other professionals;
- process payments, Medicare, NDIS or funding arrangements where applicable;
- manage complaints and feedback;
- meet legal, professional, regulatory and insurance requirements; and
- improve services and protect the safety and wellbeing of clients and others.
Information will not be used for an unrelated purpose unless the individual has provided appropriate consent or the use is otherwise permitted or required by law.
Consent, Confidentiality and Children and Young People
Where consent is required, Coastal Clarity Allied Health will seek informed consent appropriate to the circumstances. Consent should be voluntary, informed and provided by a person with appropriate authority or capacity. For children and young people, consent and information-sharing arrangements will take into account their age, development, capacity, circumstances and applicable legal and professional requirements.
Coastal Clarity Allied Health will only access, use or disclose personal information for appropriate and authorised purposes. Individuals with access to personal information must protect its confidentiality and security and only access information required for their role. Confidentiality is not absolute. Information may be disclosed without consent where required or authorised by law, including where necessary to protect a person’s safety or meet mandatory reporting or other legal obligations.
Further information about child safety and mandatory reporting is contained in the Child Safe Environments Policy.
Disclosure and Information Sharing
Coastal Clarity Allied Health may disclose personal information where:
- appropriate consent has been provided;
- disclosure is necessary to provide or coordinate services;
- disclosure is required or authorised by law; or
- disclosure is otherwise permitted under applicable privacy law.
Depending on the circumstances, information may be shared with authorised representatives, health and allied health professionals, schools or education providers, support providers, NDIS or funding bodies, insurers, government or regulatory authorities, professional advisers, technology providers, emergency services or law enforcement. Coastal Clarity Allied Health will not disclose personal information simply because another person requests it.
Website, Communication and Third-Party Systems
Coastal Clarity Allied Health may collect information through its website, including information provided through enquiry forms, email and other online interactions. Individuals are encouraged not to include unnecessary sensitive health information in general website enquiries. Coastal Clarity Allied Health uses third-party systems and service providers to support its operations, including practice management, website hosting, email and electronic records.
Coastal Clarity Allied Health currently uses Splose as its practice management system. Depending on the service provided, Splose may hold information such as client details, appointments, clinical records, documents, correspondence and invoices. Coastal Clarity will take reasonable steps to ensure that third-party systems are appropriate for the type and sensitivity of information being handled.
The website may use cookies and similar technologies for functionality, security, preferences and analytics. Electronic communication carries some risks outside Coastal Clarity Allied Health’s control, and reasonable safeguards will be used to protect information.
Photography, Recordings and Marketing
Photographs, videos and audio recordings will only be created, stored or used for legitimate purposes and with appropriate consent or legal authority. Where consent is required, individuals will be informed about the purpose of the recording and how it may be used or shared.
Personal information, photographs, recordings, testimonials or other identifying information will not be used for marketing or promotional purposes without appropriate consent or legal authority. Marketing consent will be separate from consent required to provide services.
Security, Storage and Retention
Coastal Clarity Allied Health will take reasonable steps to protect personal information from misuse, loss, unauthorised access, modification or disclosure. Security measures may include password protection, device security, restricted access, secure cloud systems, encryption, secure transmission and secure disposal. Personal information will be retained for as long as required by applicable legislation, professional requirements, funding arrangements, insurance obligations or other lawful purposes. When information is no longer required to be retained, it will be securely destroyed, deleted or de-identified as appropriate.
Privacy Breaches
A privacy breach may occur where personal information is lost, accessed, used, disclosed or modified without authorisation. Where a suspected breach occurs, Coastal Clarity Allied Health will take reasonable steps to contain the breach, assess and manage any risks, reduce potential harm and determine whether notification or other action is required. Where the Notifiable Data Breaches scheme applies, Coastal Clarity Allied Health will comply with its requirements, including notification to affected individuals and the Office of the Australian Information Commissioner where required.
Access, Correction and Privacy Complaints
Individuals may request access to personal information Coastal Clarity holds about them or request correction of information that is inaccurate, incomplete or out of date.
Privacy concerns, complaints and requests for access or correction can be made by contacting:
Email: hello@ccalliedhealth.com.au
Requests and complaints will be handled fairly and within a reasonable period in accordance with applicable privacy law. In some circumstances, access may be limited or refused where permitted or required by law.
If a person is not satisfied with Coastal Clarity Allied Health’s response to a privacy complaint, they may be entitled to contact the Office of the Australian Information Commissioner (OAIC) or another relevant regulatory body.
Responsibilities, Review and Contact
The Director is responsible for overseeing privacy and confidentiality practices at Coastal Clarity. All workers, contractors, students, volunteers and other persons authorised to access Coastal Clarity information are responsible for complying with this policy and protecting personal information.
This policy will be reviewed at least every five years and earlier where required by legislative or regulatory changes, significant privacy incidents, changes to technology or services, or identified risks.